The Disclosure and Barring Service (DBS) needed to comply with changes in the Rehabilitation of Offenders (ROA) Act 1974, and Part 5 of the Police Act 1996, and improve the efficiency and accuracy of its checks. Alongside CGI, it modernised and merged two legacy systems, migrated the rules engine to the cloud, and implemented the new ROA rules for all DBS disclosure products.
Challenge
DBS is a non-departmental public body that helps employers make safer recruitment decisions by processing and issuing DBS checks that show the criminal records of individuals who apply for certain roles or environments, such as working with children or vulnerable adults. DBS also maintains the Adults’ and Children’s Barred Lists and decides whether an individual should be barred from engaging in regulated activities with vulnerable groups.

In October 2023, reforms to the Rehabilitation of Offenders (ROA) Act came into effect, which adjusted the rehabilitation periods for different types of spent convictions, and as a result, DBS’ systems needed the ability to identify these differences and provide fair and accurate DBS checks.
Before the 2023 ROA project, the core system relied on a complex ‘rules engine’ with extremely intricate interdependencies. When the rules engine encountered a complex rule, manual intervention was required to process the application, creating a workload for administrative officers, and delaying the issuance of certificates.
The introduction of regulatory changes presented an opportunity to blend new, secure cloud technologies with a new rules’ engine without overengineering the existing DBS legacy platforms. Deadline for completion by the end of October 2023 was set in stone and the legislative needs were clear.
Solution
DBS partnered with IT and business consulting service firm CGI to deliver a cloud-based rules engine that enabled DBS to comply with the changes in the ROA Act 2023 and improve the efficiency and accuracy of DBS checks.
The project involved modernising and merging two legacy systems, migrating the rules engine to the cloud, and implementing the new ROA rules for all DBS disclosure products.
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The solution involved three main elements:
- Adding, amending, or deleting convictions and cautions being disclosed on the DBS certificate, which would help improve efficiency and customer service, and reduce the need for manual certificates
- Aligning the ROA rules applied to Standard and Enhanced certificates with those currently applied to Basic certificates, to enable any convictions and cautions not spent to be disclosed (in accordance with ROA rules)
- Implementing updates to the ROA rules to all DBS Disclosure products, i.e., Standard, Enhanced and Basics (including Update Service pseudo applications)
CGI and DBS carried out multiple ‘requirements gathering workshops’ to enable high level design documents for all three elements to be produced and needs to be met.
Outcome
The ROA project was successfully implemented on November 27, 2023, and has ensured that the DBS can continue to provide employers with the ability to make fair recruitment decisions.
The benefits so far are:
- Improvement in processing speed of DBS applications through automation
- DBS administrative officers now able to focus their expertise on more complex cases
- Faster processing of Disclosure and Barring certifications, which speeds up recruitment
- Enhanced security and scalability of the cloud-based rules engine, which can adapt to future legislative changes and technology advancements
- Improved customer satisfaction and trust in the DBS service, which helps protect the public and vulnerable groups
“The delivery of our ROA project was a major achievement for DBS, allowing us to meet key milestones in our business plan for 2023-24 and successfully operationalise legislative changes. It was a complex project, that required the combined team’s expertise and commitment to achieve,” said Barry Topham, executive director of technology and innovation at DBS.
“Delivering the programme was a major technology project for both DBS and CGI that brought significant benefits to our organisation, including efficiency and value-for-money improvements, and ultimately allowed DBS to achieve our purpose of making recruitment and employment safer while protecting the public.”